Preparing for PFAS: The next chapter of water regulation in Canada

By David Nesseth

Now that Canada has finalized its objective value threshold for 25 types of PFAS in municipal drinking water, what’s next?

But what even is an objective value? Questions are swirling.

Health Canada told Environmental Science & Engineering Magazine that objective values are based on a rapid review of new scientific research and consider international regulatory information available at the time of their development. Like guidelines, the department says that drinking water objectives are externally peer-reviewed to ensure scientific integrity. They exist to reduce potential exposure to per- and polyfluoroalkyl substances (PFAS) through drinking water, while the full guidelines are given strict focus.

Ultimately, objective values are something to strive toward, says Robert Haller, executive director of the Canadian Water and Wastewater Association (CWWA). But he says that the association’s membership is more accustomed to dealing with a Maximum Acceptable Concentration (MAC), one which enables provinces to develop enforceable regulations. That’s a point in PFAS regulation that Health Canada says could take some four to six years to reach.

“A MAC is a clear line in the sand — something measurable — where this was a little harder for us to get our heads around,” explains Haller. “It doesn’t mean we ignore it and put it on a back shelf. We’re recommending to our members to start taking action on this now.”

The action turns on a new objective of 30 nanograms per litre (ng/L), a threshold introduced and consulted on in draft form since early 2023. But it was not confirmed by Health Canada until August 2024. Municipalities can now test for all 25 listed PFAS, and when added together, they shouldn’t exceed that number.

It’s a limit that’s nearly been doubled in places such as North Bay, which has been working to remediate PFAS water contamination from firefighting foam. In 2023 the average concentration of PFAS in Trout Lake measured 56 ng/L. In other cities, like Ottawa, testing for various PFAS substances has been conducted for some five years with little results for concern. The City of Toronto has been much the same story. In 2023, there were only a handful of detectable results out of some 300 samples, with only perfluorooctanoic acid, or PFOA, registering once in the realm of the new threshold, according to Toronto’s drinking water analysis data.

PFAS Testing Challenges

Still, Haller says it’s time for Canada’s municipalities to start monitoring and determine whether there is an issue with PFAS levels. But there are challenges depending on the municipality. Fredericton, New Brunswick, for instance, is a place where testing would have to occur at a number of wells as opposed to one intake source. Haller says municipalities will need to thoughtfully target where they test and potentially study industrial impacts to determine the likelihood of PFAS in certain sources.

“If you take Toronto, and they’ve got one big pipe going out into the middle of the lake, they can test their source water out of a couple of plants. But if you go to Waterloo, they have say 100 wells and 100 potential test sites to determine the source of any potential PFAS. So, it can have a far greater impact on a community like that.”

Haller adds that PFAS requires testing from qualified labs with very specific equipment, which is not quite as simple as a lot of the standard testing that occurs locally.

Sampling should be conducted at least once per year, Health Canada recommends. It should be collected after treatment, but prior to distribution, typically at the entry point to the distribution system. Paired samples of source and treated water should be taken to confirm the efficacy of the treatment.

“The objective offers Canada’s drinking water sector an efficient approach for risk management by providing only one target value for this group of chemicals, thereby reducing exposure to PFAS and potential health risk,” said a spokesperson for Health Canada.

“It’s about empowering utilities about what is known, and what is still unknown.”

Industry Association Preparation

At the association level across Canada, flurries of factsheets, FAQs, webinars and conference speakers are emerging as the industry looks to prepare for PFAS.

Ontario Municipal Water Association (OMWA) President Justin Pulleyblank told Environmental Science & Engineering Magazine that PFAS is challenging municipal water suppliers in Ontario, but the OMWA is “working to support the Ontario water sector as they ramp up efforts to assess and deal with potential impacts on their operations.”

Pulleyblank said the OMWA, in collaboration with colleagues from its Water, Wastewater, Stormwater Equipment & Technology Advisory Council, has recently delivered virtual webinars on various operational aspects of PFAS chemicals, including potential sources and occurrence information, sampling and analytical methods, as well as treatment technologies.

The Manitoba Water and Wastewater Association held an entire day of sessions on PFAS issues in April, where speakers from the likes of ASL Global and Pinchin Ltd. shared their perspectives on how best to prepare for the changes PFAS may eventually demand.

Other associations, such as the BC Water and Waste Association (BCWWA), have formed task forces to help fast track education and awareness around PFAS. Stephen Horsman, a past president of the BCWWA and B.C. market lead for environmental engineering firm Carollo, says the eight-member task force will work to provide information and context for those in the water community who are not yet well-versed on the full scope of PFAS. The task force will get the conversation going full steam ahead, he says.

“It’s about empowering utilities about what is known, and what is still unknown,” Horsman told Environmental Science & Engineering Magazine.

Local governments do want to get out in front of the PFAS issue, but the actual exposure is not comprehensively documented, adds Horsman. Labs in Canada are working to get proper methodologies in place to sample down to the objective value.

Horsman says he currently knows of about five medium- to larger-sized utilities in B.C. that have been testing for PFAS.

“Some of the utilities that did want to get out in front of it did their sampling and said, ‘hey, you know what? We don’t have a problem. It’s good.’ However, they were screening at the higher levels, and that doesn’t necessarily speak to where we’re at now.”

Of course, the next challenge is knowing what to do with the data once municipalities have it.
“The reluctance is what’s the next step? Communications is a critical component of that. This is going to be a shared response strategy, and who takes the lead on it, and how we approach it is going to be complicated and I think challenging,” says Horsman.

A similar challenge has been on Haller’s mind, in terms of what municipalities do with PFAS once collected.

“It becomes a problem for ourselves that when we treat PFAS, it doesn’t eliminate it, it just collects it. So what do we do with those toxins out of treatment?”

Legal Action

When most people hear about PFAS these days, it’s in the same breath as lawsuits, which have been coming fast and furious. B.C. is suing PFAS manufacturers, and a class action eyeing the likes of 3M and BASF got underway in Quebec earlier this fall. B.C. Attorney General Niki Sharma said she intends for the province to lead on PFAS accountability in Canada the same way it led on civil actions “against corporations that cause widespread public harm to people in B.C., including in recent years against tobacco and opiate manufacturers.”

Even further legal battles south of the border involve water associations or utilities suing PFAS manufacturers, or water groups headed to court over the U.S. Environmental Protection Agency’s (EPA) rule itself. In April, the EPA approved even stricter drinking water standards of 4 ng/L for two particular types of PFAS called PFOS and PFOA. At the heart of that complaint is the EPA’s use of a novel “hazard index” in place of an MCL for mixtures of certain PFAS, as well as the issuing of a preliminary determination to regulate certain PFAS simultaneously with the proposed rule.

Some U.S. associations warn that the Safe Drinking Water Act does not give the EPA authority to use a hazard index as an MCL.

“The hazard index for the mixture of four PFAS in the new rule is a novel approach where the MCL is based on a sum of the ratios of four observed PFAS concentrations and each PFAS’s respective ‘health-based water concentration,’” stated the American Water Works Association in June.

When it comes to standardized methods available to quantitate PFAS compounds in drinking water, Health Canada recommends the use of EPA Method 533, as it follows current best practices related to isotope dilution and is a solid phase extraction liquid chromatography-tandem mass spectrometry method.

Treating PFAS in Water

The EPA estimates between 6% and 10% of the country’s 66,000 public drinking water systems may be subject to the new PFAS rule and need to reduce PFAS to meet the new standards. Florida and California are the states with the most people relying on public water supplies drawn from potentially contaminated groundwater sources, researchers of a fall 2024 study found using U.S. Geological Survey data. The agency, however, believes the new limits are achievable using a range of available technologies that include granular activated carbon, reverse osmosis and ion exchange systems.

Health Canada states that while there are treatment technologies that can effectively remove certain PFAS, no single treatment can remove a wide range of PFAS under all conditions. To ensure continued and effective removal, the department’s objective value report suggests that each facility should establish operational conditions and parameters based on the selected treatment technology and the characteristics of the raw water, including PFAS type, concentration and treatment goals.

“The key issues to consider when selecting treatment technologies for PFAS removal are the presence of competing anions and PFAS species, organic matter and the frequency of regeneration or replacement required for the sorptive media used,” states Health Canada.
But discovering PFAS still continues to be the first order of business.

A University of Montreal study published in 2023 analyzed PFAS contamination in tap water from 376 different municipalities in Quebec. More than 99% of the tap water samples were positive for at least one PFAS, which ranged from below detection limits to 108 ng/L. But only about 5% of the total water supply samples had levels above Canada’s new objective value.

“Achieving the objective may take time given the technical complexity and cost of measuring and managing PFAS as well as the prioritization and regulatory processes of individual jurisdictions,” said a spokesperson for Health Canada.

Over the course of the last decade Health Canada detected 13 PFAS in 566 freshwater samples, according to the objective value report. PFBA, PFPeA, PFHxA, PFHpA, PFOA and PFOS had higher detection frequencies than the other PFAS. One of the highest readings, too, was for one of these emerging subgroups: 137 ng/L for PFHxA, which is also one of the 11 problem PFAS facing North Bay, and the only other type of PFAS found in Toronto’s water last year.

As recently as September 18, the European Union restricted the use of PFHxA, although businesses will have transition periods to adapt. Officials noted the new restriction will ban the sale and use of PFHxA in consumer textiles, such as rain jackets; food packaging, like pizza boxes; consumer mixtures such as waterproofing sprays; cosmetics, like skin care products; and in some firefighting foam applications, like for training and testing, without compromising safety. It does not affect other applications of PFHxA, for example in semiconductors, batteries or fuel cells for green hydrogen.

In Canada, some efforts are already underway on a long road ahead to stop PFAS at the product stewardship level before water contamination ever becomes an issue. Alternative formulations continue to be developed; however, the federal government is requiring businesses to report on the presence of PFAS in their supply chains by January 29, 2025.

David Nesseth is a writer with Environmental Science & Engineering Magazine.

This article was published in ES&E Magazine’s November/December 2024 issue.
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